Object

Representation ID: 43825

Received: 11/10/2021

Respondent: HIMOR Group

Agent: Emery Planning

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10. Chapter 13 Sub-Areas and Site Allocations
Need for additional site allocations
10.1 As set out in our representations to Policies CSP1, HOU1 and GB1, there is a need to allocate
additional sites as part of an increased housing requirement to meet local housing need in full,
and to address the deficiencies in relation to housing land supply. Section 11 of this statement
proposes the allocation of the land at Bosty Lane, Aldridge, which would contribute to addressing
the identified shortfall.
Site selection methodology
10.2 Our concerns with the site selection methodology relate to the application of the methodology,

for Green Belt sites, the criteria for filtering our sites include:

Where development would cause very high harm to remaining Green Belt and
moderate-high or high harm to landscape sensitivity
With one or more significant planning constraints which cannot be mitigated
10.3 We have the following concerns with the approach and how it has been applied.

10.4 Firstly, the application of the methodology in the Site Assessments has significantly over-stated
harm in these categories, and/or fails to have regard to potential mitigation. The result is that
most Green Belt sites are assessed as causing very high harm to remaining Green Belt and
moderate-high or high harm to landscape sensitivity, and they are also identified as having other
insurmountable planning constraints. The assessments are unduly negative, and appear to be
part of a wider approach of over-stating harm to justify the failure to meet objectively assessed
needs within the Black Country.

10.5 Secondly, the assessments of Green Belt and landscape sensitivity rely heavily upon the
assessments of wider land in the Green Belt Study and the Landscape Sensitivity Assessment (LSA).
However, these assess much wider parcels of land and were not based on specific proposals.
Furthermore, at best they only provide a starting point of landscape sensitivity or Green Belt
contribution to a wider area. The findings of those assessments cannot be applied to the
individual site assessments in the way that they have, as the sites put forward may be lesser in


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scale than the wider parcels, follow more logical boundaries or provide mitigation such as
landscaping.

10.6 Thirdly, the BCA has applied the methodology inconsistently. For example, in Walsall:

Several sites are proposed for allocation despite being categorised as causing very high
harm to remaining Green Belt and moderate-high or high harm to landscape sensitivity,
for example the land at (South of) Stonnall Road, Aldridge (ref: SA-0309-WAL) and the .
For other sites this results in automatic filtering out.

In some instances, the presence of a SLINC across the entirety of a site is not a constraint
to allocation, for example Oxley Park Golf Club (ref: WOH261 WTNA) and land off Sutton
Road, Longwood Lane, Walsall (ref: WHA231 / Policy WSA.6). However, in other

ne, Aldridge, ref: SA-

0047-WAL).

10.7 Fourthly, the methodology does not appear to take account of the potential for a scheme to
deliver special site-specific benefits which may outweigh other considerations such as the
purported degree of Green Belt or landscape harm. Such considerations could comprise
exceptional circumstances to justify release from the Green Belt either irrespective of, or in
combination with, other factors such as meeting housing need. An example is the proposed
development of the land south of Bosty Road, Aldridge, which can deliver a replacement school
for the benefit of the local community. This should be a very significant material planning
consideration in the site selection process and the consideration of exceptional circumstances.
However, the site selection methodology does not factor this into the assessment.

10.8
site in Section 11 below.

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